Effective Date: July 9th, 2021
To review material modifications and
clarifications and their effective dates scroll to the bottom of the page.
handling practices and how we collect and use the Personal Data (defined below)
that you provide during your online and offline interactions with us.
the information practices of other companies and organizations who advertise
methodologies to serve personalized ads.
If you are a resident of the
European Economic Area (EEA) consisting of the EU, plus Norway, Iceland, and
may act as the controller if we collect Personal Data from you directly. We may
also act as the processor if we process data transmitted from our subscribers
that have contracted for access and use of our online services.
web pages. Your continued use of this site indicates your acceptance of the
Regarding Personal Data (defined
below), if any modifications are materially less restrictive regarding our use
or disclosure of the Personal Data previously disclosed by you, we will obtain
your consent before implementing such revisions with respect to such
LEGAL BASIS FOR PROCESSING PERSONAL
DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are from the European
Economic Area (EEA), our legal basis for collecting and using Personal Data
the specific context in which we collect it.
We may process your Personal Data
• We need to perform a contract with
• You have given us permission to do
• The processing is in our
legitimate interests and it’s not overridden by your rights
• For payment processing purposes
• To comply with the law
THE TYPES OF DATA WE COLLECT
“Personal Data” means data about a
living individual who can be identified from those data (or from those data and
other information either in our possession or likely to come into our
Personal Data may include, but is
not limited to:
• First name and last name
• Email address
• Phone number
• Business name
• Website URL
• Address, State, Province,
ZIP/Postal code, City
• Any Personal Data you post on our
• Any Personal Data you post on a
social media platform
• Data about how you use our website
• Technical data such as your IP
address, your login data, details about your browser, time zone settings and
other technology on the devise you use to access our website
• Your marketing and communication
• Any information that you directly
provide to us whether through our contact form, over the phone, by email or
• Geo-location data
• Cookies and Usage Data
Passively or Automatically Collected
Data (“Usage Data”).
We may also collect information
regarding how our service is accessed and used. This Usage Data may include
information such as your computer’s Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of our service that you
visit, the time and date of your visit, the time spent on those pages, unique
device identifiers and other diagnostic data.
Geo-Location Data. If you are
accessing a page from a computer or a mobile device, you may be asked to share
your precise (GPS level) geo-location information with us so we can customize
your experience when we work with a marketing partner such as a third-party
service provider, advertiser, or advertising network and platform. If you agree
to the collection of location data, in most cases, you will be able to turn off
such data collection at any time by accessing the privacy settings of your
HOW AND WHEN WE COLLECT DATA
Personal Data. We collect Personal
Data on the public areas of our site through optin forms. We may collect
publicly available Personal Data posted publicly with social media profile
Your Communications with Us. We
collect your Personal Data on the public areas of this site if you complete any
of our optin forms and/or participate in our follow-up.
Usage Data. We collect Usage Data as
you use the public areas of this site, including your interactions with emails
we send, and via social media platforms, and services of our marketing
partners. This data may be passively or automatically collected (that is,
gathered without your actively providing the information) using various
analytics and reporting technologies, such as cookies, web beacons, locally
stored objects, and mobile device identifiers and SDKs, and other similar
methodologies as well as similar technologies developed in the future. (See
below, SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS.)
HOW WE USE YOUR DATA
We may use your Personal Data
collected from the public areas of this site if you complete any of our optin
forms and/or participate in our follow-up.
We may use publicly available
Personal Data posted on social media profile information including photos for
purposes of assisting us, and our marketing partners with marketing and
advertising activities and with contact management.
RETENTION OF DATA
We will retain your Personal Data
only for as long as is necessary for the purposes set out in this Privacy
Policy. We will retain and use your Personal Data to the extent necessary to
comply with our legal obligations (for example, if we are required to retain
your data to comply with applicable laws), resolve disputes, and enforce our
legal agreements and policies.
We will also retain Usage Data for
internal analysis purposes. Usage Data is generally retained for a shorter
period of time, except when this data is used to strengthen the security or to
improve the functionality of our service, or we are legally obligated to retain
this data for longer time periods.
TRANSFER OF DATA
We are located in the United States.
Your submission of your Personal Data via this website will transfer your
Personal Data to us. We will not transfer your Personal Data outside the United
States unless the transfer is made to a country or territory recognized by the
EU as having an adequate level of data security, or is made with your consent,
or is made to satisfy our legitimate interest regarding our contractual
arrangements with our subscribers that have contracted for access and use of
our online services.
followed by your submission of your data to us signifies your agreement with
these transfers and storage of your data.
DISCLOSURE OF DATA
General Disclosure Policy. We may
share and disclose your Personal Data as described below.
Affiliated Entities. We may provide
your Personal Data and Usage Data to any affiliated entities we may have,
including our subsidiaries. Affiliated entities are entities that we legally
control (by voting rights) or that control us.
Service Providers. We may provide
access to your Personal Data and Usage Data to our trusted service providers
that assist us with the operation and maintenance of this site. For example, we
may contract with third parties to host our servers, provide security, and
optimization, analytics, reporting, and software maintenance and development
services. In addition, our service providers will be given access to your
information only as is reasonably necessary to provide the services for which
they are contracted.
Successors. If we sell or otherwise
transfer part or all of our business or assets to another organization, such as
in the course of an acquisition, merger, bankruptcy or liquidation, we may
transfer your Personal Data and Usage Data. In such an event, we will require
the buyer or transferee to agree to our commitments provided in this Privacy
Legal Process, Enforcement and
Security Notice. We may disclose your Personal Data and Usage Data if we have a
good faith belief that access, use, preservation or disclosure of such
information is reasonably necessary (i) to satisfy any applicable law,
regulation, legal process or enforceable governmental request (such as for
example, to comply with a subpoena or court order), (ii) to detect, prevent,
and address fraud or other illegal activity, and (iii) to investigate, respond
to, or enforce violations of our rights or the security of this site.
Marketing Partners. We may share
your Usage Data with our marketing partners to serve and offer personalized
ads. We may share Personal Data with our marketing partners to correlate and
match our list with our marketing partners’ lists for purposes of creating an
“audience” for serving personalized ads.
With Your Consent. We may share your
Personal Data with other parties with your consent.
YOUR DATA PROTECTION RIGHTS UNDER
THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the
European Economic Area (EEA), you have certain data protection rights. We will
take reasonable steps to allow you to correct, amend, delete, or limit the use
of your Personal Data.
If you wish to be informed what
Personal Data we hold about you and if you want it to be removed from our
systems, please contact us.
In certain circumstances, you have
the following data protection rights:
The right to access, update or to
delete the information we have on you. Whenever made possible, you can access,
update or request deletion of your Personal Data directly within your account
settings section. If you are unable to perform these actions yourself, please
contact us to assist you.
The right of rectification. You have
the right to have your information rectified if that information is inaccurate
The right to object. You have the
right to object to our processing of your Personal Data.
The right of restriction. You have
the right to request that we restrict the processing of your personal
The right to data portability. You
have the right to be provided with a copy of the information we have on you in
a structured, machine-readable and commonly used format.
The right to withdraw consent. You
also have the right to withdraw your consent at any time where we have relied
on your consent to process your personal information.
Please note that we may ask you to
verify your identity before responding to such requests.
You have the right to complain to a
Data Protection Authority about our collection and use of your Personal Data.
For more information, please contact your local data protection authority in
European Economic Area (EEA).
SPECIFIC INFORMATION ABOUT COOKIES
AND WEB BEACONS
In order to provide better service
collection methodologies discussed below to collect Usage Data to store your
preferences and information about what pages you visit and past activity at our
site and other websites. This information helps us and our marketing partners
display personalized ads, compile aggregated statistics regarding the
effectiveness of our promotional campaigns or other operations of our site. For
information about cookies from the FTC website visit –>
“Cookies” are tiny pieces of
information stored by your browser on your computer’s hard drive. Cookies are
also used to customize content based on your browser. Most browsers are
initially set to accept cookies. If you want to disable cookies, there is a
simple procedure in most browsers that allows you to turn off cookies. Please
remember, however, that cookies may be required to allow you to use certain
features of our site.
Flash Cookies – third party cookies
that use an Adobe Flash Media Player local shared object (LSO) – may be used
along with other third-party cookies for purposes of crediting any purchase you
may make on this site to one of our joint venture partners that may have
referred you to us. These cookies will be used for purposes of crediting sales
to the referring joint venture marketing partner. Flash cookies are not the
same as “browser cookies”. The Adobe Flash Media Player is software that
enables users to view content on their computers. Flash cookies are also
accompanied by a browser cookie. If you delete the browser cookie, the Flash
cookie may automatically create (or re-spawn) a replacement for the browser
Web Beacons (sometimes called
single-pixel gifs or clear gifs) are used to assist in delivering cookies, and
they allow us to count users who have visited pages of our site. We may include
Web Beacons in promotional e-mail messages or our newsletters in order to
determine whether messages have been opened and acted upon.
Locally Stored Objects – we may
employ locally stored objects (“LSOs”) and other client-side storage tracking
technologies in certain situations where they help to provide a better user experience,
such as to remember settings, preferences and usage similar to browser cookies,
or in order to target or help our Partners target ads, analyze ad performance,
or perform user, website or market analytics. For LSOs utilized by Adobe Flash
you can access Flash management tools from Adobe’s website: –>
. In addition, some, but not all browsers, provide the ability to remove LSOs,
sometimes within cookie and privacy settings.
We may participate with our
marketing partners for purposes of providing personalized ads based on your
interests. This activity is performed by collecting Usage Data and by using
cookies and other tracking and data collection methodologies discussed above to
transfer information to our marketing partners which manage advertising
Our marketing partners may also use
cookies and other tracking and data collection methodologies discussed above to
measure advertisement effectiveness and for other purposes that are disclosed
in their own privacy policies. We have no access or control over these cookies
and other tracking and data collection methodologies that may be used by our
marketing partners, and we have no responsibility or liability for the privacy
policies and practices of these sites.
AdWords (Google) – We may
participate in AdWords program which is a personalized ad service provided by
Google Inc. that connects the activity of this site with the Adwords advertising
network and the Doubleclick cookie. Information collected: cookie and Usage
Data. For the opt-out, visit –>
Google Analytics for Display
Advertising (Google) – We may participate in any and all of the following
Google Analytics Advertising Features provided by Google: Google Analytics,
Google Display Network Impression Reporting, the DoubleClick Campaign Manager
integration, and Google Analytics Demographics and Interest Reporting. These
features use first party cookies (such as the Google Analytics cookie) for
connecting the tracking activity performed by Google Analytics and its cookies
with the Adwords advertising network and the DoubleClick cookie (a third-party
cookie). Information collected: cookie and Usage Data, including audience data
such as age, gender, and interests. For the opt-out, visit –>
https://support.google.com/ads/answer/2662922?hl=en You may opt-out of the
Google Analytics service with the Google’s Browser Add-on that’s available at
For information in general about
Google’s personalized ad campaigns, and specifically about information
regarding DoubleClick cookies and how to control and manage Google’s
advertising cookies for these campaigns, visit –>
For another Google resource for
For information regarding how Google
uses data when you use Google’s partners’ sites or apps, visit –>
For an additional resource
visit –> http://www.networkadvertising.org/managing/opt_out.asp
Custom Audience (Facebook). We may
participate in Facebook.com’s Custom Audience program which enables us to
display personalized ads to persons on our email lists when they visit
Facebook.com. We provide Personal Data such as your email address and phone
number to Facebook to enable Facebook to determine if you are a registered
account holder with Facebook. You may opt-out of participation in our Facebook
Custom Audience by sending an email, from the email address you are opting out
of, to the email address provided in our contact information below. For your
opt-out to be effective, you must: (i) place the following text in the subject
line of the email – “Opting Out of Facebook.com Website Custom Audience Ads”,
and (ii) in the body of the email, include your name and email address. We will
forward your name and email address to Facebook.com with a request to delete
you from all of our Facebook Custom Audience Ads.
Tracking Programs (Twitter). We may participate in Twitter.com’s Tailored Audiences/Conversion
Tracking Programs which enable us to display personalized ads. You may opt-out
of participation in these programs by visiting
Other Personalized and Behavioral
Advertising services. We may participate in additional retargeting and
behavioral advertising services that will be similar to the services described
Managing Personalized Ads. You can
control the placement of cookies and other data collection methodologies for
purposes of opting out.
Managing Cookies Via Your Browser.
You should note that although most browsers are initially set up to accept
cookies, you may be able to change your browser settings to cause your browser
to refuse first party or third-party cookies or to indicate when a third-party
cookie is being sent. However, disabling or limiting cookies may cause certain
features of this website to not function properly or optimally. Check your
browser’s “Help” files or other similar resources to learn more about handling
cookies on your browser. In addition, visit –>
Managing Flash Cookies. Flash
cookies, also called local shared objects (LSOs), function similarly to
standard cookies except that they are often larger and are downloaded to a
computer or mobile device by the Adobe Flash Player. In some cases, these Flash
cookies can be managed through browser settings. Adobe also provides a means of
controlling Flash cookies on its Flash Player: Setting Manager page.
Network Advertising Initiative
online activities are members of NAI, which offers a single location to opt out
of receiving personalized ads from member companies. To opt out of information
collection by NAI member companies, or to obtain information about the
technologies they use or their own privacy policies, please visit the NAI
consumer opt-out page: –> http://www.networkadvertising.org/choices/
Digital Advertising Alliance (DAA).
DAA member advertising associations have developed an industry self-regulatory
program to give consumers a better understanding of and greater control over
ads that are customized based on their online behavior across different
websites. To make choices about interest-based ads from participating third
parties, please visit DAA Consumer Opt-Out page –>
Opting Out with Ad Choices for
Mobile Devices. When using mobile applications you may receive personalized
in-application advertisements. Depending on your device, you may be able to
reset your mobile device’s advertising identifier at any time by accessing the
privacy settings on your mobile device. In addition, each operating system (iOS
for Apple phones, Android for Android devices and Windows for Microsoft
devices) provides its own instructions on how to prevent the delivery of
personalized in-application advertisements. You may review the support
materials and/or the privacy settings for the respective operating systems in
order to opt-out of these advertisements. For any other devices and/or
operating systems, please visit the privacy settings for the applicable device
or contact (or review the applicable privacy web page of) the applicable
We may participate with third party
analytics partners to monitor and analyze Web traffic and to keep track of user
behavior on this site.
Google Analytics (Google) – Google
Analytics is a web analysis service provided by Google Inc. (“Google”). Google
utilizes the data collected to track and examine the use of this site, to
prepare reports on its activities, and to share them with other Google
–> https://www.google.com/intl/en/policies/?fg=1 You may opt-out of the
Google Analytics service with the Google’s Browser Add-on that’s available at
DO NOT TRACK REQUESTS
Some Web browsers incorporate a “Do Not
Track” feature that signals to websites that you visit that you do not want to
have your online activity tracked. Each browser communicates “Do Not Track”
signals to websites differently, making it unworkable to honor each and every
request correctly. In order to alleviate any communication error between
browsers and website, we do not respond to “Do Not Track” signals at this time.
As the technology and communication between browser and website improves, we
will reevaluate the ability to honor “Do Not Track” signals and may make
changes to our policy.
We will implement reasonable and
appropriate security procedures consistent with prevailing industry standards
to protect data from unauthorized access by physical and electronic intrusion.
Unfortunately, no data transmission over the Internet or method of data storage
can be guaranteed 100% secure. Therefore, while we strive to protect your
Personal Data by following generally accepted industry standards, we cannot
ensure or warrant the absolute security of any information you transmit to us
or archive at this site.
UPDATING PERSONAL DATA
Upon request, we will permit you to
request or make changes or updates to your Personal Data for legitimate
purposes. We request identification prior to approving such requests. We
reserve the right to decline any requests that are unreasonably repetitive or
systematic, require unreasonable time or effort of our technical or
administrative personnel, or undermine the privacy rights of others. We reserve
the right to permit you to access your Personal Data in any account you
establish with this site for purposes of making your own changes or updates,
and in such case, instructions for making such changes or updates will be
provided where necessary.
We do not knowingly collect
personally identifiable information from anyone under the age of 18. If you are
a parent or guardian who has discovered that your child under the age of 18 has
submitted his or her Personal Data without your permission or consent, we will
remove the information from our active list, at your request. To request the
removal of your child’s information, please contact our site as provided below
under “Contact Us”, and be sure to include in your message the same login
information that your child submitted.
Your California Privacy Rights.
Under California Law SB 27, California residents have the right to receive,
once a year, information about third parties with whom we have shared
information about you or your family for their marketing purposes during the
previous calendar year, and a description of the categories of personal
information shared. To make such a request, please send an email to the email
address provided in our contact information below and include the phrase
“California Privacy Request” in the subject line, the domain name of the
website you are inquiring about, along with your name, address and email
address. We will respond to you within thirty days of receiving such a request.
To address your individual rights or
website (at) wholesaleorprivatelabel.com